Three exemptions that exclude each other
This is not one rule with variants but three separate provisions. Using one means not using the others.
| Exempt | Cap | Duration | For whom | |
|---|---|---|---|---|
| 8(23A) | 50 % | none | 17 years | remuneration above €55,000 |
| 8(21A) | 20 % | €8,550 a year | 7 years | first employment by 31.12.2027 |
| 8(21B) | 25 % | €25,000 a year | 7 years | returnees |
The threshold fell in 2022, not 2026
Here many overviews quote the wrong year, and it comes from the fact that something did happen in 2026, only elsewhere.
What happened in 2022: the threshold of the 50 percent exemption fell from €100,000 to €55,000, and the duration rose to 17 years. Published in the Official Gazette on 26 July 2022, retroactive to 1 January 2022.
What happened in 2023: an amendment of 30 June 2023, also retroactive to 1 January 2022, raised the prior non-residence from 10 to 15 years and replaced the term “first employment” with “any employment”.
What happened in 2026: to Article 8(23A), nothing. What was added is the new exemption under Article 8(21B).
The 50 percent exemption in detail
The threshold is tested annually. If remuneration falls below €55,000 in a year, the exemption drops out for that year. It revives as soon as remuneration is above it again. So it is not lost for good.
It may be reached in the first or the second year. Anyone just below in the starting year does not lose it automatically.
50 % of the entire remuneration is exempt, not only the part above €55,000. The €55,000 is an entry condition, not a tax-free allowance.
The new 25 percent rule is for returnees
Article 8(21B) came in through Law 17(I)/2026, and it is regularly described as a “new expat regime”. That is misleading.
The condition has two parts:
- The person must not have been tax resident in Cyprus in the seven years before.
- The person must have been resident at some point before that.
Anyone who has never lived in Cyprus fails the second condition and does not qualify. The rule targets Cypriots and former residents coming back, not new arrivals.
Further conditions: income above €30,000, employment beginning between 1 January 2025 and 31 December 2030, duration of seven years, that is the year of commencement and the six following. It applies to employment income and to profits from self-employment, which distinguishes it from the other two.
What we could not substantiate
- The wording “15 of the preceding 20 years”. Several presentations from 2026 describe the non-residence that way. The sources resting on the 2023 amending law speak of 15 consecutive years immediately before. We follow the second reading and record the conflict.
- The starting year of the 20 percent exemption. One source writes that it begins in the year after the employment starts. Others name the year of commencement. We did not check this against the statutory text.
- Whether the 25 percent exemption runs from the year of commencement. A KPMG publication quotes seven years without a starting point.
Which of the three rules applies in your case, and whether it applies, decides a great deal of money over years. That belongs with somebody who knows the case: Cyprus setup from one place.
What else counts alongside
The exemption concerns income tax on employment income. It does not concern:
- the GHS contribution, which falls on total income
- social insurance
- the special defence contribution, from which non-dom status exempts you, see the guide to non-dom status
Whether somebody becomes resident in Cyprus at all is in the guide to tax residency. What arises on payroll is in the guide to payroll.
